November 12, 2002
CLA-2-84:RR:NC:1:110 I87344CATEGORY:CLASSIFICATIONTARIFF NO.:8472.30.0000
Ms. Stacy L. Weinberg
Mr. David M. Murphy
Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP 245 Park Avenue, 33rd Floor
New York, NY 10167-3397RE: The tariff classification of paper handling/bulk mailing machines from Sweden.
Dear Ms. Weinberg and Mr. Murphy:
In your letters dated September 20 and October 16, 2002, on behalf of your client Pitney Bowes, Inc., you requested a tariff classification ruling.
The merchandise under consideration is the FASTPAC Inserting System that consists of four components parts number: F600, F601, F602 and F620. These units are imported in one configuration grouped together into a single system used exclusively for the FASTPAC Inserting System.
The FASTPAC Inserting System is a multi-unit production mailing machine used for collating various papers and inserting the papers into large envelopes. From the information provided with your ruling request, the FASTPAC Inserting System is a free standing unit with adjustable wheel casters, for leveling purposes and locking into place. Part number F600 is the inserter component for the base unit, F601 is the inserter component for the booklet feeder, F602 is the collating feature and part number F620 is the power pack. The FASTPAC Inserting System is a functional unit under Sec. XVI, Note 4. Its principal function is the insertion of mail into envelopes.
The Harmonized Commodity Description and Coding System Explanatory Notes (“EN’s”) constitute the official interpretation of the Harmonized System at the international level. While neither legally binding nor dispositive, the EN’s provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. Noting EN 84.72, the term “office machines” is to be taken in a wide general sense to include all machines used in offices, shops, factories, workshops, etc., for doing “office work” (i.e. work concerning the writing, recording, sorting, etc.). EN 84.72 further states that office machines are classified here only if they have a base for fixing or for placing on a table, desk, etc. The FASTPAC Inserting System appears to satisfy the EN’s, because it has adjustable wheel casters that firmly support the base and affix this system into position.
The applicable subheading for the FASTPAC Inserting System part numbers F600, F601, F602 and F620 will be 8472.30.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other office machinesMachines for sorting or folding mail or for inserting mail in envelopes or bands, machines for opening, closing or sealing mail and machines for affixing or canceling postage stamps.” The rate of duty will be 1.8 percent ad valorem.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Eileen S. Kaplan at 646-733-3016.
Sincerely,
Robert B. Swierupski
Director,